Compliance calendar
SEBIInsider trading and takeovers

Trade disclosure by the company to the stock exchange

The company's onward disclosure to the exchanges of a trade reported to it by a promoter, director or designated person.

How this is timed

Disclosure to the stock exchanges

Counted from receipt of the Reg 7(2)(a) intimation, or the company becoming aware of the trade

Regulator
SEBI
Category
Insider trading and takeovers
Form
Not specified
Last verified
2026-09-01

Two trading days from receiving the intimation. Under PIT Reg 7(2)(b) the company notifies every stock exchange where its securities are listed within two trading days of receiving the information under Reg 7(2)(a) or becoming aware of it. Most companies no longer file this by hand: system-driven disclosures cover it, and from 4 May 2026 NSE requires any residual filing to go through a mandatory XBRL utility on NEAPS.

What changed

The regulation has not changed but the filing route changed twice. System-driven disclosures took the manual filing out for compliant companies, and NSE circular NSE/CML/2026/12 made the residual filing a mandatory XBRL submission through NEAPS from 4 May 2026. Whether BSE made the same move is not established.

Deadlines counted from an event

These have no calendar date. The clock starts when the event happens.

Disclosure to the stock exchangesfrom receipt of the Reg 7(2)(a) intimation, or the company becoming aware of the trade

Within two trading days of receiving the information under Reg 7(2)(a) or of becoming aware of the trade, notify every stock exchange on which the securities are listed. The trading-day count makes any computed date an estimate.

The rule

Stated as the law states it, so you can work out any period yourself.

Disclosure to the stock exchanges

Within two trading days of receiving the information under Reg 7(2)(a) or of becoming aware of the trade, notify every stock exchange on which the securities are listed. The trading-day count makes any computed date an estimate.

Who must comply

  • Every listed company that receives a Reg 7(2)(a) intimation or otherwise becomes aware of a reportable trade

Carve-outs

  • Paragraph 4.3.7 of the Master Circular on Surveillance of Securities Market makes manual filing under Reg 7(2)(a) and 7(2)(b) non-mandatory for companies whose system-driven disclosures are working

Statutory basis

Read the provision here where we hold it, or on the regulator's site.

Before you file

  • Get the Form C intimation from the person who traded.
  • Check the holdings figures before and after the trade.
  • Get access to the exchange filing utility.
  • Check whether the system-driven disclosure already covers this trade.

How to file

  1. 1Record the date on which the company received the intimation.
  2. 2Prepare the disclosure in the format the exchange utility requires.
  3. 3Submit the disclosure through the NSE XBRL utility on NEAPS.
  4. 4Submit the same disclosure to every other exchange where the securities are listed.
  5. 5Do this within two trading days of receipt.

NSE NEAPS XBRL utility, and the BSE Listing Centre

If you miss it

SEBI adjudicates this under section 15A(b) of the SEBI Act, at ₹1 lakh for each day the failure continues, capped at ₹1 crore, because the company is required by the regulations to furnish the information within a specified time. Section 15HB is the fallback at up to ₹1 crore. There is no per-day exchange fine: the Chapter VII Section VII-A fine table in the LODR Master Circular covers LODR regulations, and Reg 7(2)(b) is a PIT provision.

  • The disclosure is public, so a gap in the exchange filing is visible to the market and to SEBI's surveillance systems without any inspection
  • A pattern of late filings feeds the compliance officer's report to the board or the audit committee chair under clause 1 of Schedule B

Recent changes affecting this

From the regulator's own circulars and notifications.

sebi15 May 2026Master circular

Master Circular on Surveillance of Securities Market

This Master Circular consolidates SEBI's regulatory framework for securities market surveillance, covering trading rules, monitoring of unauthenticated news, financial disincentives for Market Infrastructure Institutions (MIIs), and disclosure requirements under the SEBI (Prohibition of Insider Trading) Regulations, 2015. It mandates internal controls for market intermediaries to prevent the circulation of unauthenticated news and establishes a framework for financial disincentives when MIIs fail to meet surveillance obligations. The circular also details automated system-driven disclosures and the mandatory freezing of Permanent Account Numbers (PAN) for Designated Persons and their immediate relatives during trading window closure periods. Previous circulars listed in the appendix are rescinded, though actions taken under them remain valid.

Common questions

When is the Reg 7(2)(b) disclosure due?

Within two trading days of the company receiving the intimation from the person who traded, or of the company becoming aware of the trade.

Does the company still have to file this manually?

Often not. Paragraph 4.3.7 of the Master Circular on Surveillance of Securities Market makes manual filing non-mandatory where system-driven disclosures are working. Where a filing is still needed, NSE has required it to go through an XBRL utility on NEAPS since 4 May 2026.

Last verified 2026-09-01. Confirm against the official source before you rely on it.